The purpose of a Section 4(f) draft evaluation is to offer a description of a given project, as well as a description of the property affected by the project, and the relevant impacts and alternatives. The draft evaluation does not identify the selected alternative; that discussion is reserved for the next step in the evaluation process, the final evaluation.

When putting an evaluation together as part of the NEPA document, make sure your Section 4(f) information is consistent with other references and information throughout the rest of the EA or EIS. Also, be aware that all Section 4(f) evaluations must undergo a legal sufficiency review by the Federal Highway Administration (FHWA). The review is intended to ensure that Section 4(f) and NEPA requirements have been met, in case of a legal challenge to Section 4(f) use. The data collected as part of the evaluation may be used for legal purposes if necessary.

Below is a list of elements required for a draft evaluation. They should be addressed in the following order:

Introduction
As a general guideline, consider beginning a Section 4(f) evaluation by paraphrasing or directly quoting the following statement:

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Description of Proposed Action
For a separate Section 4(f) evaluation, describe the proposed project alternatives, and explain the purpose and need for the project. For an evaluation submitted with an EIS or EA/FONSI, briefly summarize and reference the section of the National Environmental Policy Act (NEPA) document that contains additional detail about the project area and proposed alternatives.

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Description of Section 4(f) Resources
Describe each Section 4(f) resource that would be subject to use by any alternative under consideration. Be sure to include the following information:

Be sure to quantify measurable impacts such as noise and affected functions whenever possible. Impacts such as visual intrusions, which cannot be quantified, should be described.

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Avoidance & Minimization Alternatives
A Section 4(f) evaluation must demonstrate that avoidance and minimization alternatives to the project under consideration have been evaluated. With respect to avoidance alternatives, specifically, the evaluation must include a discussion that will ultimately support a determination of whether or not an avoidance alternative is feasible and prudent in the final evaluiation.

A determination that no feasible and prudent avoidance alternatives exist is generally withheld until after the draft evaluation has been circulated to the appropriate agencies and all issues have been appropriately evaluated.

This discussion of feasibility and prudence must note whether any avoidance alternatives present unique problems or are prohibitively expensive, extraordinarily disruptive to the community, somehow impractical or objectionable, or inadequate to meet the project purpose and need.

Finally, the draft evaluation should address all possible measures to minimize harm, including a separate discussion of each impact to a Section 4(f) resource. For example, if multiple public parks are affected, a separate discussion of each park should be provided, detailing how impacts will be minimized. Be sure to include a least harm analysis to show how efforts were made to minimize impacts to each alternative.

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Mitigation
All mitigation measures require appropriate documentation and coordination between the state transportation agency and the official with jurisdiction, including the State Historic Preservation Officer (SHPO) when cultural resources are involved.

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Coordination
Discuss the results of coordination with the following parties:

If any of these agencies raise issues during coordination, Section 4(f) requires follow-up coordination. While the statute does not stipulate that these issues be resolved successfully, it does require reasonable efforts and good-faith attention by decision makers.

Generally, the coordination should include a discussion of avoidance alternatives, impacts to the property, and mitigation measures. In addition, coordination with the public official with jurisdiction should include, where necessary, a discussion of significance and primary use of the property.